Published

In mid-January 2016, the Democratic Republic of Congo submitted its revised Emission Reductions Programme Document (ER-PD) to the Carbon Fund of the World Bank’s Forest Carbon Partnership Facility. The Environmental Investigation Agency has produced a report of “preliminary comments” on the ER-PD.

EIA recommends that it would be “premature” for the Carbon Fund, at its meeting in June 2016, to decide to start negotiations about an Emission Reduction Payment Agreement with DRC. Below is EIA’s summary of its concerns. EIA’s full preliminary comments report can be downloaded here.

EIA notes that DRC’s ER-PD plays down the impact of industrial logging. EIA raises particular concern about the remarks by Robert Bopolo Bogeza, DRC’s Minister of Environment, Nature Conservation and Sustainable Development, that measures are underway to lift DRC’s moratorium on logging concessions and open up the country’s forests to industrial logging.

Instead of focussing on the destruction caused by industrial logging, the ER-PD assumes that shifting cultivators are the primary drivers of deforestation. EIA writes that, “The main interventions are targeted at getting people to give up their traditional livelihoods and shift from subsistence agriculture in the forest to agro-forestry schemes involving cash crops on the savannahs.”

Perhaps even more shocking is the fact that industrial logging in primary forests could increase while logging companies would profit from REDD payments. As EIA points out,

This could lead to continued deforestation and degradation (hence program failure) as well as the issuing of “hot air” credits, which would be detrimental to the whole REDD+ effort internationally, in addition of course to the damage to DRC’s forests.

It’s worth adding that “hot air” REDD credits would lead to increased greenhouse gas emissions and therefore increased climate change. Emissions would increase through the logging in DRC’s forests as well as from the continued pollution in rich countries that the REDD credits are supposed to offset.

Preliminary comments by the Environmental Investigation Agency on the Democratic Republic of the Congo’s Emission Reduction Program Document for the World Bank Forest Carbon Partnership Facility, final draft dated January 2016

We commend the government of the DRC for the progress made in developing the program in the new Mai Ndombe province proposed for funding through an Emission Reduction Payment Agreement (ERPA) with the Carbon Fund (CF). We note with great concern however the 30th January statements by DRC’s Minister of Environment, Nature Conservation and Sustainable Development, Robert Bopolo Mbongeza, that discussions are underway to lift the moratorium on the allocation of logging concessions as this will greatly undermine any REDD+ efforts in the country.

We strongly recommend however that the CF14 meeting in June would be premature for CF Participants to make a decision to begin ERPA negotiations with DRC because additional work is needed to justify the high forest/low deforestation adjustment, to substantiate the carbon accounting, to clarify the analysis of drivers, to align the proposed program strategies with the drivers analysis, to carry out detailed land tenure assessments in the ER Program area, to develop more specific safeguards and benefit sharing plans, and to establish a functioning grievance mechanism, among other issues needing further attention.

We present below the results of a preliminary analysis of the emission reduction program document (ER-PD). We look forward to sharing further inputs by the time of the next Participants Committee meeting and to discussions of these issues ahead of CF14.

Summary of Concerns

The upward adjustment of the reference level above historical averages is not sufficiently justified, and the data used to support it are not clear or transparently presented.

The proposed methodologies for carbon accounting are also not transparent and are not fully aligned with the emerging national forest monitoring and MRV system.

The analysis of drivers blames most deforestation on poor shifting cultivators when this does not appear to be supported by the data presented.

The proposed program measures and budgets are misaligned to the drivers, focusing mostly on limiting subsistence shifting cultivation, with insufficient attention to industrial logging, artisanal logging and the broader governance reforms needed to reduce corruption and illegality in the forest sector and secure legal rights to land and forests for local communities and indigenous peoples.

The analysis of industrial logging concessions has little discussion of illegality in the sector, problems with corruption, transparency and human rights abuses.

The assessment of land tenure in the ER program area required by the CF methodological framework (criteria 28) has not been carried out and the information provided in the strategic environmental and social assessment report, the environmental and social management framework or its component resettlement framework and indigenous peoples planning framework, the frameworks for the FIP projects, the Bio-Carbon Fund Feasibility Study or social assessments for the Dedicated Grant Mechanism for Indigenous Peoples, as well as the ER-PD itself, are high level summaries of general information with little detail and almost no site specific information for the Mai Ndombe province.

The proposed measures to address land tenure insecurity are vague and do not seem to be rooted in actions that will lead to permanent legal recognition of community and indigenous lands, rather towards sanctioning temporary land uses through local development plans ratified by provincial authorities.

The Government does not propose the recognition of the carbon rights of communities or indigenous peoples, undercutting their basis for sharing in ER program revenues.

The benefit sharing plans still require further development, while the principles seem sound, the proposed indicative division of resources seems inequitable, privileging the project holders and logging concessions over communities.

The safeguard framework requires further development, the documents that exist are national level frameworks, with insufficient detail on time bound, place specific actions that will take place in the ER Program area. Safeguard implementation appears to be delegated to local executing agencies that are independent of government, undercutting the need to build permanent public sector capacity for social and environmental management.

The program level grievance mechanism, required through the March 2011 Readiness Preparation Grant is still not operational, as required by the CF Methodological Framework.

Corruption risk and elite capture, identified as a real concern for the REDD+ process in DRC, is not addressed in the ER-PD in a substantive way, so that neither the anticorruption measures to be implemented at the program level nor the anticipated progress at the national level are clear.